News & Analysis as of

Consent Order Regulation Z

Ballard Spahr LLP

CFPB Takes Action Against BloomTech, Inc. for ISAs that Violate TILA, UDAAP, and the FTC’s Holder Rule

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On April 17th, the CFPB issued a consent order to a for-profit training school alleging numerous violations of law related to its use if income share agreements (“ISAs”). According to the Bureau, BloomTech, Inc. (“BloomTech”)...more

Goodwin

2023 Year in Review: Credit, Debit, or Prepaid Cards and Consumer Banking

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Welcome to the Credit, Debit, or Prepaid Cards and Consumer Banking chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - We expect continued focus by the CFPB on “junk”...more

Shipkevich PLLC

End of the Year for the CFPB? Not Yet! Another Order Obtained Against a Student Loan Service Provider

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On November 20, 2023, the Consumer Financial Protection Bureau (“CFPB”) announced that it had partnered with the 11 States of California, Delaware, Illinois, Massachusetts, Minnesota, North Carolina, Oregon, South Carolina,...more

Hudson Cook, LLP

CFPB Fines Large National Bank for Withholding Credit Card Rewards, Charging Multiple Non-sufficient Fund Fees, and Opening...

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On July 11, 2023, the CFPB announced two consent orders against a large national bank, settling allegations that the bank illegally charged consumers multiple non-sufficient fund fees for the same transaction, withheld cash...more

Goodwin

CFPB Enters Into $15 Million Settlement with Auto Lender

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On February 23, 2023, the Consumer Financial Protection Bureau (CFPB) announced that it entered into a consent order​ with an auto lender based in Georgia....more

Bradley Arant Boult Cummings LLP

CFPB Action Against Student Loan Originator Sends Message to Income Share Agreement Industry

On September 7, 2021, the CFPB issued a consent order against Better Future Forward, Inc., and related entities (collectively, BFF), companies that provide financing for postsecondary education to students via income share...more

Ballard Spahr LLP

CFPB Alleges Income Share Agreements are Extensions of Credit in Results-Oriented Enforcement Action against ISA Originator

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The CFPB issued a consent order against an income share agreement (ISA) provider, Better Future Forward (BFF), in which it concluded that BFF’s ISAs are extensions of credit under the Consumer Financial Protection Act and...more

Goodwin

CFPB Enters Into Consent Order with Mortgage Lender for $140,000

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On April 27, 2021, the Consumer Financial Protection Bureau (CFPB) announced that it had entered into a consent order with a reverse mortgage broker and lender, resolving allegations that the company violated the Mortgages...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

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In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

Ballard Spahr LLP

CFPB Issues Additional Consent Orders for False and Misleading Mortgage Advertising

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Since late July, the CFPB has issued seven consent orders against mortgage companies in which the CFPB asserts that the companies engaged in false and misleading advertising to service members and veterans. ...more

Ballard Spahr LLP

CFPB Issues Additional Consent Order for False and Misleading Mortgage Advertising

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On August 21, 2020, the CFPB announced the issuance of a consent order against Go Direct Lenders, Inc. (Go Direct). This follows consent orders discussed in a previous blog post, that were announced on July 24, 2020 against...more

Ballard Spahr LLP

CFPB Issues Consent Orders for False and Misleading Advertising for VA Mortgages

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On July 24, 2020, the CFPB announced the issuance of consent orders against Sovereign Lending Group, Inc. (Sovereign) and Prime Choice Funding, Inc. (Prime Choice). The CFPB indicated in their announcement that these consent...more

Goodwin

CFPB Announces $1.1 Million Settlement with California-based Lenders to Resolve Allegations of Unfair and Deceptive Practices

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On July 24, 2020, the Consumer Financial Protection Bureau (CFPB) announced that it entered consent orders (here and here) against two California-based mortgage lenders, resolving allegations that the lenders violated the...more

Goodwin

CFPB Settles with Colorado Mortgage Servicer for $1.52M for Alleged RESPA Violations

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On May 11, 2020, the Consumer Financial Protection Bureau (CFPB) settled with a Colorado-based mortgage servicer that serviced a portfolio of mortgage loans worth approximately $112.69 billion. According to the CFPB, the...more

Goodwin

FDIC Enters Into $20 Million Consent Order With Debt Settlement Entities

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On March 28, 2018, the Federal Deposit Insurance Corporation (“FDIC”) annou?nced settlements with a bank and an affiliated lender (“Defendants”) relating to allegations of deceptive lending practices. According to the FDIC,...more

Ballard Spahr LLP

CFPB and Virginia AG settle claims against pawnbroker for alleged TILA/CFPA/VA law violations

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The CFPB and the Virginia Attorney General announced that they had entered into a proposed consent order with  Woodbridge Coins and Jewelry Exchange, Inc., a Virginia-based pawnbroker, to settle a lawsuit filed in a Virginia...more

Ballard Spahr LLP

CFPB settles with military financing company for alleged TILA/EFTA disclosure violations

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The CFPB announced that it has entered into a consent order with Military Credit Services, LLC, a company providing revolving credit to military consumers, to settle allegations that the company’s open-end credit agreements...more

Ballard Spahr LLP

Company that entered into CFPB consent order loses motion to dismiss class action

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A California federal judge has rejected the attempt of Castle & Cooke Mortgage, LLC, the mortgage company that entered into a consent order with the CFPB in November 2013 to settle charges that it violated the Regulation Z...more

Ballard Spahr LLP

CFPB takes aim (again) at loan originator compensation

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Two days after announcing a proposed consent order with a mortgage company and its CEO to settle charges that the company paid bonuses and higher commissions to loan officers in violation of the Regulation Z loan originator...more

Ballard Spahr LLP

CFPB settles loan originator compensation case

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The CFPB has entered into a proposed consent order with a mortgage company and its CEO to settle charges that the company paid bonuses and higher commissions to loan officers in violation of the Regulation Z loan originator...more

MoFo Reenforcement

Strike Two for Alleged L.O. Comp. Violations

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Last week, the Bureau announced a $730,000 settlement with Franklin Loan Corporation (Franklin) based on alleged violations of the loan originator compensation rule in Regulation Z. That rule prohibits mortgage lenders from...more

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